{"query_echo":{"q":"","filters":{"analysis_type":["stakeholder feedback"]},"warnings":[{"code":"facet_value_not_in_vocabulary","message":"Value 'stakeholder feedback' for facet 'analysis_type' is not in the controlled vocabulary."}]},"total":{"value":4,"relation":"eq"},"page":1,"page_size":20,"self":"https://climateinsightsdirectory.org/api/v1/search?analysis_type=stakeholder+feedback","stability":"beta","ai_marking":{"digital_source_type":{"uri":"http://cv.iptc.org/newscodes/digitalsourcetype/trainedAlgorithmicMedia","name":"Created using Generative AI"},"notice":"Summary and key insights are generated using artificial intelligence."},"results":[{"id":"ember-000340","url":"https://climateinsightsdirectory.org/document/ember-000340","title":"Response to Just Energy Transition Partnership Indonesia Progress Report 2025","publisher":{"name":"Ember","organization":"ember"},"document_type":"statement","language":"en","date_published":"2025-11-24","source_url":"https://ember-energy.org/app/uploads/2025/11/Letter-–-Indonesia-JETP-2025.pdf","generator":"Climate Insights Directory","generated_fields":["summary","key_insights","climate_tags","geography_discussed","analysis_type"],"summary":{"text":"Ember argues that Indonesia's energy transition requires more ambitious emissions targets and a stronger regulatory framework, particularly for the underregulated captive coal sector. The organization recommends integrating JETP investments with long-term economic diversification in coal-dependent provinces to ensure a just transition. Ember also highlights a significant gap in solar deployment, noting that Indonesia reached only 416 MW of on-grid solar capacity last year against a 2025 target of 4.1 GW, and calls for more transparent procurement processes by PLN.","ai_generated":true,"unit":"ember-000340#summary","date_modified":"2026-10-23"},"key_insights":[{"text":"Indonesia's current solar energy deployment is significantly lagging behind JETP targets; the country achieved only 416 MW of on-grid solar capacity last year, while the JETP target for 2025 is 4.1 GW and for 2030 is 29.3 GW.","ai_generated":true,"unit":"ember-000340#insight-1","date_modified":"2026-10-23"},{"text":"The captive coal sector presents a major opportunity for decarbonisation, with an estimated solar PV potential of 496.3 GWp. Integrating 9.4 GW of new solar with 6.8 GW of older coal capacity could reduce emissions by 35% within two years, a reduction equivalent to the annual power sector emissions of Brunei.","ai_generated":true,"unit":"ember-000340#insight-2","date_modified":"2026-10-23"},{"text":"There is a misalignment between JETP objectives and Indonesia's national planning documents, such as the National Electricity Masterplan (RUKN), National Energy Policy (KEN), and the Second NDC. While JETP aims for power-sector emissions to peak before 2030, national planning projects a peak around 2037.","ai_generated":true,"unit":"ember-000340#insight-3","date_modified":"2026-10-23"},{"text":"The current Just Transition Framework is considered too narrow because it focuses on project-level interventions rather than system-wide impacts in regions structurally tied to fossil fuels. Ember recommends aligning JETP investments with regional diversification strategies to mitigate risks like job losses and shrinking local revenues in coal-dependent provinces.","ai_generated":true,"unit":"ember-000340#insight-4","date_modified":"2026-10-23"},{"text":"Captive coal capacity is projected to grow to 32 GW by 2031 and remains generally underregulated. Ember recommends implementing emission caps, expanding the Emissions Trading Scheme (ETS) to cover captive power, and enforcing emission-reduction obligations under Presidential Regulation No. 112/2022.","ai_generated":true,"unit":"ember-000340#insight-5","date_modified":"2026-10-23"}],"climate_tags":["Just Energy Transition Partnership","Coal phase-out","photovoltaics","emission trading","power purchase agreement","just transition","economic diversity","climate finance"],"geography_discussed":["Brunei"],"frame_perspective":[],"analysis_type":["policy analysis","stakeholder feedback"]},{"id":"cmw-000560","url":"https://climateinsightsdirectory.org/document/cmw-000560","title":"LOST IN DOCUMENTATION","publisher":{"name":"Carbon Market Watch","organization":"carbon-market-watch"},"document_type":"report","language":"en","date_published":"2024-03","source_url":"https://carbonmarketwatch.org/wp-content/uploads/2024/04/CMW-Lost-in-Documentation-Transparency-in-voluntary-carbon-market-registries.pdf","generator":"Climate Insights Directory","generated_fields":["summary","key_insights","climate_tags","analysis_type"],"summary":{"text":"The report evaluates transparency in the voluntary carbon market (VCM) by analyzing a sample of 140 projects across the Verified Carbon Standard (VCS), Gold Standard (GS), American Carbon Registry (ACR), and Climate Action Reserve (CAR). It finds that no single standard provides full disclosure, with significant gaps caused by both inadequate rule-setting and insufficient enforcement. Specifically, CAR and ACR have structural limitations regarding the public disclosure of monitoring reports. The study also identifies widespread issues with mislabelled, duplicated, or missing documents, which rating agencies confirm hinder the independent assessment of carbon credit quality. The report recommends implementing stronger quality assurance/quality control (QA/QC) processes, standardized naming conventions, and regular audits to align with Integrity Council for Voluntary Carbon Markets (ICVCM) requirements.","ai_generated":true,"unit":"cmw-000560#summary","date_modified":"2026-10-23"},"key_insights":[{"text":"No major voluntary carbon market standard provides full disclosure of project documentation, although transparency levels vary significantly between them.","ai_generated":true,"unit":"cmw-000560#insight-1","date_modified":"2026-10-23"},{"text":"The analysis of 140 projects revealed a total of 444 missing project documents, with issues stemming from both a lack of mandatory disclosure rules and a failure to enforce existing rules.","ai_generated":true,"unit":"cmw-000560#insight-2","date_modified":"2026-10-23"},{"text":"Structural transparency limitations exist in the ACR and CAR registries; CAR does not mandate public disclosure of monitoring reports, and ACR only requires it for reporting periods ending after July 1, 2023.","ai_generated":true,"unit":"cmw-000560#insight-3","date_modified":"2026-10-23"},{"text":"When evaluating only documents mandated for disclosure by all standards (Project Design Documents, Validation Reports, and Verification Reports), VCS was the best performer with 0.39 missing documents per project, followed by CAR (0.44), ACR (0.64), and GS (0.74).","ai_generated":true,"unit":"cmw-000560#insight-4","date_modified":"2026-10-23"},{"text":"An average of 51% of credit batches lacked a corresponding monitoring report across the sample, though this drops to 5.6% when limited to standards that actually mandate their publication (GS and VCS).","ai_generated":true,"unit":"cmw-000560#insight-5","date_modified":"2026-10-23"},{"text":"Registry documentation is frequently plagued by administrative errors, including mislabelled or mis-categorised files, duplicates, and incorrect project locations, particularly within the Gold Standard registry.","ai_generated":true,"unit":"cmw-000560#insight-6","date_modified":"2026-10-23"},{"text":"Feedback from rating agencies (BeZero, Calyx Global, and Sylvera) confirms that missing or outdated documentation complicates the rating process and that there is a lack of clear communication channels for requesting missing data.","ai_generated":true,"unit":"cmw-000560#insight-7","date_modified":"2026-10-23"}],"climate_tags":["carbon offset","transparency"],"geography_discussed":[],"frame_perspective":[],"analysis_type":["comparative analysis","audit","stakeholder feedback"]},{"id":"cmw-000424","url":"https://climateinsightsdirectory.org/document/cmw-000424","title":"Free Allocation Regulation (FAR) revision","publisher":{"name":"Carbon Market Watch","organization":"carbon-market-watch"},"document_type":"statement","language":"en","date_published":"2023-12-19","source_url":"https://carbonmarketwatch.org/wp-content/uploads/2023/12/20231218-CMW-feedback-on-FAR.pdf","generator":"Climate Insights Directory","generated_fields":["summary","key_insights","climate_tags","analysis_type"],"summary":{"text":"Carbon Market Watch (CMW) opposes the current draft of the Free Allocation Regulation (FAR) revision, stating it increases free allowances for industrial sectors and contradicts the political mandate of the EU ETS Directive. CMW identifies critical failures in steel and cement benchmarking, the use of median production levels for Historical Activity Level (HAL) calculations, and an insufficiently ambitious reduction in free allowances for process emissions.","ai_generated":true,"unit":"cmw-000424#summary","date_modified":"2026-10-23"},"key_insights":[{"text":"The current FAR proposal is viewed as a 'watering down' of previous texts, resulting in increased free allowances for incumbent industrial sectors and a failure to align with the political mandate of the EU ETS Directive review.","ai_generated":true,"unit":"cmw-000424#insight-1","date_modified":"2026-10-23"},{"text":"Steel benchmarks fail to follow the 'one product = one benchmark' principle because they remain linked to production processes, specifically benchmarking hot metal/DRI rather than flat steel output, which CMW argues hinders GHG emission reductions and scrap re-use.","ai_generated":true,"unit":"cmw-000424#insight-2","date_modified":"2026-10-23"},{"text":"Cement benchmarks are criticized for being expressed in tons of clinker, which CMW claims penalizes most supplementary cementitious materials (SCMs) and fails to support technological innovations that lower the most polluting components of cement manufacturing.","ai_generated":true,"unit":"cmw-000424#insight-3","date_modified":"2026-10-23"},{"text":"The proposal to calculate Historical Activity Level (HAL) using a median level of annual production instead of an arithmetic average is seen as a regulatory inconsistency that would lead to the overallocation of free allowances by ignoring production drops during the pandemic and energy price crisis.","ai_generated":true,"unit":"cmw-000424#insight-4","date_modified":"2026-10-23"},{"text":"The proposed reduction value for process emissions not covered by product benchmarks is considered too lenient at 91% with enforcement only from 2028, especially compared to earlier proposals of 79%, which CMW argues will undermine the decarbonisation of heavily polluting processes.","ai_generated":true,"unit":"cmw-000424#insight-5","date_modified":"2026-10-23"}],"climate_tags":["European Union Emission Trading Scheme 1","Industrial decarbonization","carbon leakage","iron and steel industry","green hydrogen"],"geography_discussed":[],"frame_perspective":[],"analysis_type":["policy analysis","stakeholder feedback"]},{"id":"cmw-000404","url":"https://climateinsightsdirectory.org/document/cmw-000404","title":"Industrial Emissions Directive","publisher":{"name":"Carbon Market Watch","organization":"carbon-market-watch"},"document_type":"statement","language":"en","date_published":"2022-06-23","source_url":"https://carbonmarketwatch.org/wp-content/uploads/2022/09/090166e5ede2a90d.pdf","generator":"Climate Insights Directory","generated_fields":["summary","key_insights","climate_tags","analysis_type"],"summary":{"text":"Carbon Market Watch argues that the European Commission's proposal to revise the Industrial Emissions Directive (IED) fails to meaningfully address greenhouse gas (GHG) emissions because it maintains the exclusion of GHGs from installations covered by the EU Emissions Trading System (ETS). The organization recommends deleting Article 9.1 to allow binding emission limits for ETS sectors, maintaining the deletion of Article 9.2 to make energy efficiency requirements mandatory, and strengthening the requirements for industrial transformation plans (TP) to ensure they are binding, detailed, and implemented before 2030.","ai_generated":true,"unit":"cmw-000404#summary","date_modified":"2026-10-23"},"key_insights":[{"text":"The current proposal for the IED revision fails to meaningfully address greenhouse gas emissions because it retains Article 9.1, which excludes GHGs from installations already covered by the EU ETS. Carbon Market Watch argues that the Commission's decision to delay the integration of the IED's command-and-control approach with the ETS market-based system until 2028 provides no beneficial impact on the climate or environment.","ai_generated":true,"unit":"cmw-000404#insight-1","date_modified":"2026-10-23"},{"text":"Carbon Market Watch disputes the Commission's claim that binding emission limits for ETS sectors would harm the efficiency of the carbon market. It asserts that the EU ETS already possesses mechanisms to manage market oversupply, and that combining the IED with a strong ETS would accelerate industrial decarbonisation and emission reductions.","ai_generated":true,"unit":"cmw-000404#insight-2","date_modified":"2026-10-23"},{"text":"The proposed introduction of transformation plans (TP) for operators is considered insufficient due to vague objectives, a timeline that may push implementation to 2034, and a non-binding regime. The document argues that TPs should be ready by 2025, include clear milestones and indicators, and be reflected in permits to make them binding and enforceable.","ai_generated":true,"unit":"cmw-000404#insight-3","date_modified":"2026-10-23"},{"text":"The document supports the deletion of Article 9.2, which would remove the option for member states to decide whether to impose binding energy efficiency requirements, thereby making such requirements mandatory for all covered installations.","ai_generated":true,"unit":"cmw-000404#insight-4","date_modified":"2026-10-23"}],"climate_tags":["industrial emission","greenhouse gas emissions","European Union Emission Trading Scheme 1","energy efficiency","Industrial decarbonization"],"geography_discussed":[],"frame_perspective":[],"analysis_type":["policy analysis","stakeholder feedback"]}]}